MHC, Inc. v. UMWA, 685 F.Supp. 1370 (E.D. KY 1988)
Early RICO case brought as result of UMWA violence. Court found that a pattern of violence requires "multiple episodes evincing a regular and ongoing course of conduct." Court held that violent acts such as murder and arson support a RICO claim and are sufficiently independent of labor law so as not to be preempted by it.